Blair v. Labor Commission
2011 UT App 248
Utah Ct. App.2011Background
- Ollie Blair sought medical and disability compensation for a back condition he links to a 1999 industrial accident.
- The Labor Commission denied Blair’s 2007 application for benefits.
- Blair argued respondents admitted causation in their answer, which would waive causation as an issue.
- Respondents admitted liability for Blair’s claim and paid medical and disability benefits, but denied Blair’s causation theory.
- A Medical Panel concluded Blair’s 2007 symptoms were unrelated to the 1999 accident, asserting a pre-existing degenerative condition.
- The ALJ and the Commission adopted the Medical Panel’s findings but Blair challenged the Panel’s view on causation and the adequacy of findings.
- The Utah Court of Appeals reversed in part and remanded for additional findings addressing Blair’s challenges to the Medical Panel’s causation conclusion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether causation was effectively admitted | Blair: Respondents admitted causation in answer | Respondents: pleadings were imprecise; causation was not explicitly admitted | Not waived; Commission’s handling within bounds of reasonableness |
| Whether causation is an affirmative defense requiring Rule 602-2-1C2 pleading | Causation was improperly treated as an affirmative defense | Respondents challenged causation within proper pleading scope | Causation is not an affirmative defense; rule 602-2-1C2 does not apply to causation |
| Whether the wrong legal standard was applied to causation | Standard should be the natural result (Allen) rather than medical causation | Panel’s approach sufficiently addresses natural-result causation | Any error was harmless; standard effectively satisfied |
| Whether interim findings adequately addressed eight-year history of symptoms | Interim findings should detail eight-year leg and back symptoms | Medical Panel had the record and conducted appropriate evaluation | Harmless error; panel based its conclusions on the records supplied |
| Whether Commission sufficiently explained why Medical Panel discounted contrary evidence | Findings inadequate; Blair’s objections about eight-year history were not addressed | Commission adopted Medical Panel findings and relied on their expertise | Reversed and remanded to provide more detailed findings addressing Blair’s objections |
Key Cases Cited
- Barnard & Burk Group, Inc. v. Labor Comm'n, 122 P.3d 700 (Utah Ct. App. 2005) (upholding Commission’s denial within reasonableness bounds)
- Pilcher v. State Dep't of Soc. Servs., 663 P.2d 450 (Utah 1983) (liberal construction of administrative pleadings)
- Fox v. Brigham Young Univ., 176 P.3d 446 (Utah App. 2007) (causation not treated as an affirmative defense)
- Allen v. Industrial Comm'n, 729 P.2d 15 (Utah 1986) (medical causation standard for work-related disability)
- Nyrehn v. Industrial Comm'n, 800 P.2d 330 (Utah Ct. App. 1990) (requires detailed findings to permit appellate review)
- Resort Retainers v. Labor Commission, 238 P.3d 1081 (Utah Ct. App. 2010) (agency may adopt medical panel findings but must consider other evidence)